texas commission on environmental quality - TCEQ e-Services

More documents

Recommendations

Info

Section 2.5.2 and Appendix 2.6.1. 3. Comment: The application in Volume 1, p. 2-41, describes “minor volcanism in Trans- Pecos Texas and northeastern New Mexico” as occurring “between about 27 and 31 million years ago” and references Henry and Price, 1985. A reference check indicates that this reference does not characterize the volcanism as minor (especially as it continues well into Mexico), says little or nothing about northeastern New Mexico, and states that “most of the activity, including all caldera formation, was between 38 and 28 m.y.a.” Requested Action: The Applicant did not revise the text, as stated. Instead, the reference was completely omitted. Please include the reference, using the correct dates. 4. Comment: We were unable to find Table 1, “Fault Source Parameters for the WCS Analysis,” in Volume 2B, Appendix 2.5.2. Requested Action: Please provide the table, or direct us to where it can be found in the application. 5. Comment: Answered in TNOD1 response. 6. Comment: Answered in TNOD1 response. 7. Comment: Answered in TNOD1 response. 8. Comment: Answered in TNOD1 response. 9. Comment: Answered in TNOD1 response. 10. Comment: It is not clear from Volume 3, Figure 6.4-11 how deep the main reverse fault propagates into the Dockum. Requested Action: Application materials have provided some evidence of distributed shear upward with loss of displacement on the main fault planes. Please explain the evidence that there is also loss of displacement on the main fault planes downward, and how it has been demonstrated that displacement does not, in fact, increase downward. 11. Comment: From Figure 6.4-11 in Volume 3, it appears that the sandstone cut by the main fault may intersect with the southern sidewall of the FWF. Requested Action: The Applicant’s response states that this sandstone is present in B 32/32A and B-60. Figure 6.4-11 in Volume 3 has the top of the sandstone at approximately 32 feet below the top of Dockum and dipping northward at the north end of the figure. The Attachment 2 Second Technical Notice of Deficiency 1/30/2006 Page 25 of 51
first sandstone below the top of Dockum in B-32 is at about 76 feet below top of Dockum. Please identify whether this is the same sandstone. Also, we could find no such boring as B 60 on any of the figures. Please identify B-60 on figures. The text of the application should discuss the expected existence of this sandstone in the sidewall of the proposed FWF. 12. Comment: The text in Volume 3, pages 4-6 to 4-7 describes “well-developed joints at about 0.5 to 1 foot spacing” that are part of an “orthogonal regional jointing system” and a set of lower angle, “wavy” joints. On the June 2005 field trip, gypsum veins, one centimeter or more in width, were noted in joints in the Cooper Canyon Formation in the RCRA excavation, indicating that these structural features were fluid-filled at some time in the past. This observation seems to conflict with statements in the application that swelling montmorillonite clays and small fracture apertures preclude or severely limit the potential for fracture flow. Requested Action: • The Applicant’s response seems to contend that all naturally occurring (i.e., not induced by excavation) fractures and joints were developed under saturated conditions. Please provide evidence to support this contention. • The Applicant’s response does not address fracture aperture. Fracture aperture is an important issue for modeling and performance assessment, and the RCRA pit is one place where the Applicant can obtain real data to evaluate this parameter. Please address fracture aperture at the proposed site. • Please explain what is the mechanical impact of gypsum on the swelling argument to close fractures. Please address possible voids in the middle of the vein that would remain open even under saturated conditions, assuming swelling closes the fractures elsewhere. • Please explain what the impact of gypsum is on the modeling results indicating that water movement will be considerably slowed by matrix imbibition into the clay matrix. TOUGH2 modeling considers that matrix imbibition retards water movement so much that other parameters are unimportant. This problem is similar to the impact of coatings on flow. • Swelling is also a function of the ionic strength of the surrounding water. A clay will not swell if ionic strength is above some threshold. Since swelling is such an important aspect of the model, please add demonstrative discussion on this topic. 13. Comment: Answered in TNOD1 response. 14. Comment: Answered in TNOD1 response. 15. Comment: The Applicant in its response advocates a “remarkable” coincidence of a buried feature with modern topography. Attachment 2 Second Technical Notice of Deficiency 1/30/2006 Page 26 of 51
Page 1 and 2: Kathleen Hartnett White, Chairman R
Page 3 and 4: Attachment 1 Second Technical Notic
Page 5 and 6: the federal government will assume
Page 7 and 8: institute condemnation proceedings
Page 9 and 10: 8. Comment: The following oil and g
Page 11 and 12: Requested Action: Please provide a
Page 13 and 14: Leland. Furnish an affidavit of ide
Page 15 and 16: approximately 10 km from the site s
Page 17 and 18: three of the census tracts (CT-1, C
Page 19 and 20: than heterogeneity, in conclusions
Page 21 and 22: adiation? ;(4) How might low-level
Page 23 and 24: Although the table provides three c
Page 25 and 26: costs for increased preparation for
Page 27 and 28: 24. Comment: In response to TNOD1,
Page 29 and 30: 1. Comment: Volume 2A, Appendix 2.3
Page 31 and 32: excavation and the proposed FWF and
Page 33 and 34: The occurrence of OAG groundwater i
Page 35 and 36: over a geologic feature referred to
Page 37: Requested Action: Please discuss in
Page 41 and 42: Demonstrate that the disposal site
Page 43 and 44: 7. Comment: Answered in TNOD1 respo
Page 45 and 46: Requested Action: It is unclear fro
Page 47 and 48: Volume 1, Section 2.7.2, when Secti
Page 49 and 50: approximately 750 feet east of the
Page 51 and 52: Dutton AR. 1995. Groundwater isotop
Page 53 and 54: hydraulic conductivity (according t
Page 55 and 56: unit into that zone. Also, such flo
Page 57 and 58: confidence interval for the mean of
Page 59 and 60: Requested Action: Please submit rel
Page 61 and 62: have little or no value 500, 1,000,
Page 63 and 64: “non-detect,” but which in this
Page 65 and 66: Attachment 3 Second Technical Notic
Page 67 and 68: in Appendix E of API 650). Also, in
Page 69 and 70: evidence is available to support th
Page 71 and 72: issues noted above. Refer to the De
Page 73 and 74: Two strategies for limiting such vo
Page 75 and 76: additional analyses. 17. Comment: T
Page 77 and 78: intended service life considerably
Page 79 and 80: additional analyses. 36. Comment: T
Page 81 and 82: Requested Action: Please submit rel
Page 83 and 84: additional analyses. Section 3.6 3.
Page 85 and 86: that an “average condition runoff
Page 87 and 88: • Please provide an analysis whic
Page 89 and 90:
11. Comment: Answered in TNOD1 resp
Page 91 and 92:
• Appendix 4.2.3, Part 2.7-A.2 (R
Page 93 and 94:
and could possibly detect the stabi
Page 95 and 96:
Requested Action: Please provide th
Page 97 and 98:
include concrete, rebar, grout, san
Page 99 and 100:
16. Comment: Volume 9A, OP-3.0, pag
Page 101 and 102:
Section 5.2.3 A description of how
Page 103 and 104:
waste is transferred from the rail
Page 105 and 106:
Requested Action: The Applicant par
Page 107 and 108:
The Applicant can only seek approva
Page 109 and 110:
Requirements,” states that the us
Page 111 and 112:
Format and Content of a license app
Page 113 and 114:
individual responsible for making o
Page 115 and 116:
Requested Action: Please provide me
Page 117 and 118:
4. Comment: Answered in TNOD1 respo
Page 119 and 120:
Design Features and Operating Proce
Page 121 and 122:
facility that include cloth PPE. (N
Page 123 and 124:
Manager and because the Health & Sa
Page 125 and 126:
6. New Comment: Some pagination in
Page 127 and 128:
Attachment 7 Second Technical Notic
Page 129 and 130:
the period of institutional control
Page 131 and 132:
In Paragraph 5.1.5.1 the Applicant
Page 133 and 134:
commonly applied to radiological da
Page 135 and 136:
dependent on the sample size availa
Page 137 and 138:
set of data indicating a radionucli
Page 139 and 140:
plan will establish precise actions
Page 141 and 142:
(1.18 in/yr), the erosion of the ea
Page 143 and 144:
ability of the site to meet perform
Page 145 and 146:
4. Comment: Answered in TNOD1 respo
Page 147 and 148:
14. New Comment: The Applicant may
Page 149 and 150:
adioactivity in effluents from the
Page 151 and 152:
Requested Action: See comment 6 abo
Page 153 and 154:
and shipment conditions and charact
Page 155 and 156:
hazardous mixed waste constituents
Page 157 and 158:
upon descriptions of volumes of was
Page 159 and 160:
portion or all of the resident intr
Page 161 and 162:
determination of 7,800 years for ve
Page 163 and 164:
Attachment 9 Second Technical Notic
Page 165 and 166:
pressures resulting from cost and s
Page 167 and 168:
The WCS inspection service contract
Page 169 and 170:
(1) Design review; (2) Peer review;
Page 171 and 172:
not prevent the Applicant from subm
Page 173 and 174:
4. New Comment: Volume 11A, Appendi
Page 175 and 176:
(1) Adjustment and calibration usin
Page 177 and 178:
Attachment 10 Second Technical Noti
Page 179 and 180:
6. New Comment: Neither document de
Page 181 and 182:
Attachment 11 Second Technical Noti
Page 183 and 184:
Hydrology, Hydorgeology: • The Ap
Page 185 and 186:
13. New Comment: The application in
Page 187 and 188:
Requested Action: Please provide a
Page 189 and 190:
licenses.” Requested Action: Plea
Page 191 and 192:
Requested Action: What is the basis
Page 193 and 194:
would require that the full actual
Page 195 and 196:
discounted dollars for two reasons.
Page 197 and 198:
protection, and other necessary eng
Page 199 and 200:
time value of money to meet full fu
Page 201:
Note: Cost estimates as expressed i
show all

texas commission on environmental quality - TCEQ e-Services

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?